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MACRA: Proposed Changes to the Merit-Based Incentive Payment System Track

The Centers for Medicare & Medicaid Services (CMS) published a proposed rule on the Medicare Quality Payment Program (QPP) in the Federal Register1 on June 30, 2017. This rule proposes the QPP program requirements for...more

Making Sense of the MACRA Final Rule – Part 3 of 3: Merit Based Payment Incentive System (MIPS)

The Centers for Medicare & Medicaid Services (CMS) recently released its final rule with comment period implementing the bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Among its numerous changes,...more

Recent Enforcement Action: Business Associates Not Off the Hook

Despite the fact that Business Associates have been directly subject to and liable under the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (HIPAA) since February 18, 2010 the...more

Understanding the Implications of MACRA, MIPS and APMs

On May 9, 2016, the Centers for Medicare & Medicaid Services (CMS) published a notice of proposed rulemaking to implement the bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Although the...more

Phase 2 of the OCR HIPAA Audit Program Already Underway

On March 21, 2016, the Department of Health and Human Services, Office for Civil Rights (OCR) announced the launch of the long-awaited Phase 2 HIPAA Audit Program (Phase 2), and OCR activities related to Phase 2 are already...more

Failure to Follow HIPAA Policies Results in $150,000 Liability and Corrective Action Plan

The U.S. Department of Health and Human Services, Office for Civil Rights (HHS-OCR) has recently released information about another HIPAA settlement, emphasizing yet again the government's focus on the Health Insurance...more

Stolen Thumb Drive Sets HIPAA Precedent

A Massachusetts dermatology practice, Adult & Pediatric Dermatology, P.C. ("APDerm") recently agreed to pay $150,000 to settle potential violations of HIPAA Privacy, Security, and Breach Notification Rules. The settlement was...more

Health Reform + Related Health Policy News - January 2014, Issue 1

In This Issue: - Top News ..Congress Approves Budget Deal with Short-Term ‘Doc Fix' ..CMS “Two-Midnight” Rule delayed until March 31, 2014 ..Individuals with Canceled Insurance Policies May Apply for...more

Under The New HIPAA Regime, A Lost Laptop Costs $1.5 Million But A Leased Photocopier Costs Almost As Much

Nearly one year after a Massachusetts provider paid $1.5 million to settle potential HIPAA violations for the theft of an unencrypted laptop containing protected health information (PHI), providers are reminded once again of...more

Breaking Down The HIPAA Rule Changes: Part 5 Of 5 - Changes To Patients' Rights Under The Final Rule

In This Issue: - Right to Access Protected Health Information - Restrictions on Health Plan Disclosures - Guidance on How to Comply With the Expanded Patient Rights ..Evaluate Electronic Systems ..Revise...more

Breaking Down The HIPAA Rule Changes: Part 4 Of 5 - Uses And Disclosures Of PHI Under The Final Rule; Changes Related To...

In This Issue: - Modifications Related to the Use and Disclosure of PHI for Marketing Purposes - Modifications Related to the Use and Disclosure of PHI for Research Purposes ..Compound Authorizations...more

Breaking Down The HIPAA Rule Changes: Part 3 Of 5 Modifications To The Breach Notification Rule

In This Issue: - Definition of “Unsecured Protected Health Information” - Notice Requirements - Action Items to Comply with the Breach Notification - Excerpt from Definition of “Unsecured Protected Health...more

Breaking Down The HIPAA Rule Changes: Part 2 Of 5 - Changes Affecting Who Is A Business Associate And New Business Associate...

In This Issue: - Expansion of, Clarifications to, and Explicit Inclusions in the Definition of BA - BAs’ Direct Liability Under the Final Rule - BAAs: Required Provisions Under the Final Rule and the Compliance...more

Breaking Down The HIPAA Changes: Part 1 Of 5 What Covered Entities And Business Associates Need To Do To Comply With The Final...

In This Issue: - Brief Overview of Key Modifications in the Final Rule - Suggested Action Items for Compliance with the Final Rule ..Covered Entities ..Business Associates - Consequences of Noncompliance...more

Final Omnibus HIPAA Rule Released By HHS

On January 17, 2013, the U.S. Department of Health and Human Services (HHS) issued an advance copy of the final omnibus rule which implements changes to the Health Insurance Portability and Accountability Act of 1996, and the...more

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